Page 1 of 13 February 10 , 2016

Good D rones LLC 202 Meserole Street, Suite 1 Brooklyn, NY 11206 (516) 263

- 5690 | Goodrones@gmail.com

U. S. Department of Transportation Docket Management System

1200 New Jersey Avenue, SE Washington, DC 20590

RE: Petition of Good D rones LLC for Exemption Pursuant to Section 333 of the

FAA Modernization and Reform Act of 2012 and Part 11 of the Federal Aviation Regulations

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “ Reform Act ” )

and 14 C F R Part 11

, Good Drones LLC hereby applies for an exemption from the Federal Aviation Regulations (“FARs”)

, identified below, to allow commercial operations of small unmanned aircraft system s (“UASs”). This exemption accords with protocols published by the Federal Aviation Administration (FAA), the enclosed UAS manufacturer’s operations and instructions manuals, the UAS quick start guides, and any other requir ement established by the

FAA.

As described more fully below, the request ed exemption would permit comme rcial operation by

Good Drones LLC (“Good Drones”) to conduct UAS education, humanitarian work, communication, photography, videography and film production, and geographical surveying under controlled conditions in airspace that are (1) limited, (2) predetermined, and (3) controlled

as to access

. Moreover, Good Drones ’ operation, under th e exemption, will be subject to strict operating requirements and conditions to ensure an equivalent level of safety to currently authorized operation using manned aircraft and under conditions as may be modified by the FAA as required by Section 333. Good D r ones respectfully requests that any part deemed not in

com pliance be removed and the remaining portion of this request be processed as applicable.

Additionally, the FAA issued Mehdi Salehi, CEO of Good Drones, a “sUAS Certificate of Registration” on December 21, 2015, certificate number FA334ML943.Page 2 of 13 Good Drones has organized this exemption request as follows:

I. Petitioner’s Description 2

II. Relevant Statutory Authority 3

III. Qualifications for Approval Under Section 333 of the Reform Act 3

IV. Description of Proposed Operations 4

V. Regulations from Which Exemption is Requested 6

VI. Public Interest 12

VII. Federal Registry Summary 12

VIII. Conclusio n 13

I. Petitioner’s Description

Goo d Drones LLC, headquartered in Brooklyn , New York , is a company that leverages drone technology to improve lives. To fulfill this mission, Good Drones provides drone education and develops technical solutions to humanitarian crises. For example, Good Drones is developing a

real

- time monitoring and data

- sharing platform to ensure the safe arrival of r efugees to the Greek

Island of L esb os. Further, Good Drones undertakes environmental monitoring through aerial photography and videography; supports research, design, and innovation; and, performs aerial filming for site inspections. Good Drones has also c reated a drone affixed with a screen for communication and advertisement applications.

Mehdi Salehi, Co

- Founder and CEO, has been a leader in the application of drone technology to today’s most pressing problems as an Adjunct Professor at Parson s Design and Technology Program at The New School in New York . He teaches masters

- level classes on drone technology, where students conceptualize and execute socially beneficial projects with drone technology. This s pring 2016 semester , students focus on pro jects related to environmental mapping to create 3D models, virtual reality spaces, and 3D

- printed scale models.

Good Drones’ goal is to operate in an accident

- free environment by:

• Demonstrating a commitment by management and all employees to operate in a compliant manner ;

• Identifying hazards and risks, while eliminating or controlling all these risks; and

,

• Training all employees involved in flight operations to operate at the highest standard

level.

The contact information for Petitioner follows :

Good Drones LLC 202 Meserole Street, Suite 1 Brooklyn, NY 11206

Mehdi Salehi, Co

- Founder

Email: Mehdi@goodrones.com

Tel.: (516) 263

- 5690Page 3 of 13 II. Relevant Statutory Authority

This petition for exemption is submitted to fulfill Congress’s goal in passing Sections 333(a)

- (c) of the Reform Act. Congress directed the FAA “to safely accelerate the integration of civil unmanned aircraft systems into the national airspace system.” Reform Act § 332(a). Pursuant to

t hat section, the Secretary of Transportation consider s whether certain UAS may operate safely in the national airspace system (“NAS”)

, before completion of t he formal UAS rulemaking under

S ection 332 of the Reform Act . The Secretary must determine which types of UASs do not create a hazard to NAS users or to the public or pose a threat to national security based on: (1) the UAS’s size, weight, speed, and operational capacity; (2) operation of the UAS in close proximity to airports and populated areas; and , (3) operation of he UAS within the visual line of sight of the operator. § 333 (a), (b)(1).

If the Secretary determines that such vehicles “may operate safely in the National Airspace System, the Secretary shall establish requirements for the safe opera tion of such aircraft in the National Airspace System.” § 333(c) (emphasis added). 1

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This statutory authority, by its terms, includes exempting civil aircraft, as defined under Section 40101 of the Act, from the requirement that all civil aircraft have a current airworthiness

certificate and from those regulations requiring commercial pilots to operate aircraft in

commercial service

. See 49 U.S.C. § 44701(f) (“ The Administrator may grant an exemption from a requirement of a regulation prescribed under subsection (a) or (b) of this section or any of

sections 44702

– 44716 of this title if the Administrator finds the exemption is in the public

interest. ”).

III. Qualificatio ns for Approval

The proposed operations in this petition for exemption qualify for approval. Each of the statutory

criteria and other relevant factors are satisfied.

The proposed operations would permit Good Drones to use its UAS s under controlled condit ions in airspace that are (1) predetermined and (2) controlled as t o access as well as (3) provide an increased level of safety beyond that of existing fixed

- or rotor

- wing employed to accomplish the

same purpose.

Good Drones’ UASs are rotorcraft, weighin g 55 lbs or less, including payload

. Specifically, Good Drones operates two commercially available models: Phantom 3 Professional

, manufactured by DJI, and Inspire 1, also manufactured by DJI. The UASs operate, under normal

conditions at a speed no more than 50 knots . They have the capability to hover and move in the vertical and horizontal planes. They will operate in line of sight, duri ng daylight hours, and!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!! 1 Good Drones interprets this provision to place a duty on the Administrator to both process applications for exemptions as well as to craft conditions for the safe operation of the UAS. If the Administrator deems the conditions proposed herein require modif ication to permit approval for an exemption under Section 333, Good Drones welcomes the opportunity to consult with FAA staff to address issues or concerns this proposal may raise and thus may require modification.Page 4 of 13 within an area described in the enclosed Manufacturers’ Operations Manual s (the “Manual s ”),

atta ched as Exhibit 1. Further, the UASs will operate at or below 400 feet above ground level,

and Good Drones will file a Notice to Airmen (NOTAM) for each flight operated in controlled airspace, a s required. Such operations will ensure that the UASs will “no t create a hazard to users of the national airspace system or the public.” Reform Act § 333(b)

.

Given the small size of UASs involved and the restricted environment within which they will

operate, Good Drones’ flights would achieve an equivalent level of safety to that envisioned by Congress, whereby the FAA must, by exemption, allow commercial operations of UASs to commence, pending completion of formal rulemaking. Given the clear direction of Section 333 of the Reform Act, the auth ority conferred under the Federal Aviation Act, the equivalent level of safety surrounding Good Drones’ proposed operations, and the significant public benefit, the grant of the requested exemption would be with in the public interest.

IV. Description of Prop osed Operations

The enclosed Manual s describe , in detail, the policies and procedures for Good Drones’ proposed UAS operations. To assist the FAA in its safety assessment, below is a summary of operational limits and conditions that will ensure an equival ent or higher level of safety to operations conduced under current regulatory guidelines:

(1) The UAS will weigh 55 lbs or less

. (2) Flights will be operated within line of sight of the Operator

. (3) Maximum total flight time will be limited to the amount of time the UAS may be flown

and still maintain a reserve batter y power of no les than 25%.

(4) Flights will be operated at an altitude of no more than 5 00 feet above ground level or no more than 200 feet above an elevated platform from which flying is planned.

(5) Flights will be operated at a safe lateral distance from any inhabited structures, buildings, vehicles, vessels, or people not associated with the operation or who have not signed a

waiver or assented to an oral waiver in advance of the operation.

(6) The UAS Pilot with Pilot in Command responsibilities for the flight will be the designated “Operator”).

(7) The Operator will have been trained in the operations of the UAS generally and received

up

- to

- date information on the particular UAS to b e operated, as detaile d in the M anuals.

(8) The UAS will operate only within a confined area described in the Manuals.

(9) A briefing will be conducted as to the planned UAS operations prior to each day’s activities. It will be mandatory that all personnel who will be performing duties within

the confined a rea be present.

(10) All UASs will be maintained in accordance with the inspection program specified in

Good Drones’ Manual s and in compliance with the manufacturer’s guidelines.

(11) All required permissions and permit s will be obtained from t err itorial, state, county, or city jurisdictions, including local law enforcement, fire, or other appropriate governmental agencies.Page 5 of 13 (12) If the UAS loses communications sight, the UAS will have the capability to return to a predetermined location to land.

(13) The UAS has the capability to abort a flight in case of unpredicted obstacles or emergencies.

Further , Good Drones will control the UASs with transmitters that comply with Part 15 of

Federal Communication Commission rules. Good Drones’ UAS radio transmitters are compliant with regulations governing radio transmitters in the 2.400GHz to 2.4835GHz frequency range

. When operating transmitters, the Operator will maintain a separation distance of at least 5 cm between his body and the antenna.

V. Regulations from Which Exemption is Requested

Good Drones seeks relief from the following requirements of Part 11 of the Federal Aviation
Regulations:

14 CFR Part 21, Subpart H

14 CFR § 45.23(b)

14 CFR § 61.113 (a), (b)

14 CFR § 91.7

14 CFR § 91.205(a), (b), (c)

14 CFR §§ 91.405(a); 91.407(a)(1); 91.407(a)(2); 91.417(a), (b)

14 CFR § 91.203(a), (b)

14 CFR § 91.151(a)

14 CFR § 9 1.121

14 CFR § 9 1.119

14 CFR § 91 .109

14 CFR § 91. 103

14 CFR § 91.9(b)(2)Page 6 of 13 A. 14 CFR Part 21, Subpart H : Airworthiness Certificates

Subpart H established procedural requirements for the issuance of airworthiness certificates as required by FAR § 91.203(a)(1). Provided the size and limited operating area associated with the aircraft to be used by Good Drones, an exemption from this subp art meets the requirements of an equivalent level of safety under Part 11of the FAR and Section 333 of the Reform Act. The latter along with 49 U.S.C. § 44701(f) authorize the FAA to exempt aircraft from the requirement of an airworthiness certificate, upo n consideration of the size, weight, speed, operational capability, and proximity to airports and populated areas. In all cases, the UAS operated without an airworthiness certificate in a restricted environment and under fixed conditions proposed will be

a t least as safe, or safer, than a conventional aircraft operating with such a certification but without such proposed restrictions and conditions.

Equivalent Level of Safety

The UASs to be operated weigh 55 lbs or less, fully loaded, carry neither pilot nor passenger s , carry no explosive materials or flammable liquid fuels, and operate exclusively within a predetermined area. Unlike other civil aircraft, operations under this exemption will be tightly controlled and monitored by the Operator , pursuant to the Manual s , and in compliance with local public safety requirements. These safety enhancements provide a greater degree of safety to the public and property owners than conventional operations conducted with airworthiness

certificates issued under 14 CFR Part 21, Subpart H. Lastly, application of these same criteria demonstrates there is no credible threat to national security posed by the UAS due to its size, speed of operation, location of operation, lac of explosive or flammable materials, and inability to carry a substantial load.

B. 14 CFR § 45.23(b) : Marking of the Aircraft

Under 14 CFR § 45.23(b), an aircraft must be marked as follows:

When marks include only the Roman capital letter “N” and the registration number is displayed on limited, restric ted or light

- sport category aircraft or experimental or provisionally certificated aircraft, the operator must also display on that aircraft near each entrance to the cabin, cockpit, or pilot station, in letters

not less than 2 inches nor more than 6 inche s high, the words “limited,” “restricted,” “light

- sport,” “experimental,” or “provisional,” as applicable.

Although Good Drones’ UAS will lack an airworthiness certificate, an exemption may be necessary since the UAS will have no entrance to cabin, cockpi t or pilot station on which to write. Further, given the small size of the UAS, two

- inch lettering will be impossible.

Equivalent Level of Safety

To assure an equivalent level of safety, the UAS will be identified by serial number, registered in

accordan ce with 14 CFR Part 47, and have identification numbers (N

- Number) markings in accordance with 14 CFR Part 45, Subpart C, which will be made as large as practicable.Page 7 of 13 C. 14 CFR § 61.113 (a), (b): Private Pilot Privileges and Limitations: Pilot in

Command

Sections 61.113 (a) and (b) limit private pilots to non

- commercial operations.

Equivalent Level of Safety

Good Drones submits that the proposed operations can achieve the equivalent level of safety by requiring the Operator to have a private pilot’s license rather than a commercial pilot’s license.

Unlike a conventional aircraft that carries a pilot, passengers, and cargo, UASs are remotely

controlled with neither passengers n or cargo on board. The area of operation is contr olled and restricted, and all flights are planned and coordinated in advance, as set forth in the Manual s . The risks associated with the operation of the UAS are diminished from the level of risk associated with commercial operations contemplated by Part 6 1 . The operations of the UAS with a private pilot license, as requested

, exceeds the present level of safety achieved by 14 CFR § 61.113 (a) and (b).

D. 14 CFR § 91.7: Civil Aircraft Airworthiness

Under 14 CFR § 91.7, no person may operate a civil aircraft unless it is in airworthy condition

. To the extent that there will be no airworthiness certificate issued for UAS, should this request for exemption be granted, no FAA regulatory standard will exist to determine airw orthiness.

Equivalent Level of Safety

Should Good Drones’ request for an exemption from an airworthiness certificate be granted, no FAA regulatory standard will exist to determine airworthiness. Considering the small size of the aircraft and requirements contained in the Manual s as to maintenance and use of pre

- flight safety checklists, an equivalent level of safety will be provided.

The FAA has issued exemptions to this regulation, including Exemption Nos. 9299A, 10700, and

32827.

E. 14 CFR § 91.9(b)( 2): Civil Aircraft Flight Manual in the Aircraft

Section 91.9(b)(2) of the FAR provides:

No person may operate a U.S.

- registered civil aircraft . . . [f] or which an Airplane or Rotorcraft Flight Manual is not required by§ 21.5 of this chapter, unless there is available in the aircraft a current approved Airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any combination thereof.Page 8 of 13 Equivalent Level of Safety

Given the size of Good Drones’ UASs, configuration, and load capacity, the UASs have no place to carry such a flight manual on the aircraft. Instead, an equivalent level of safety will be maintained by keeping the M anual s at a ground control point where the Operator will have

immediate access.

The FAA has issued exemptions to this regulation, including Exemption Nos. 8737, 32827, and 111333 (“documents required under 14 CFR §§ 91.9 and 91.203 must be available to the PIC [“Pilot in Command,” or Operator] at the Ground Control Station of the UAS any time the aircraft is operating.”).

F. 14 CFR § 91. 103: Preflight Action

Section § 91.103 require s each Pilot in Command (“PIC”) to take certain actions before flight to ensure flight safety, including that the PIC must familiarize him or herself with takeoff and landing data in an “approved Airplane or Roto r craft Flight Manual.” See 14 CFR § 91.103(b)(1).

Equivalent Level of Safe ty

Should Good Drones’ request for an exemption from storing a flight manual in the UAS be granted, an exemption under 14 CFR § 91.103 is necessary. An equivalent level of safety will be

achieved by following the Manuals, and the Operator will take all re quired preflight actions

— including reviewing weather data, landing and takeoff distance, and aircraft performance data

— before flight. Further, the Manual will be kept at a ground control point where the Operator will

have immediate access.

G. 14 CFR § 91

. 109: Flight Instruction

Section § 91.109 provides that no person may operate a civil aircraft used for flight instruction unless that aircraft has fully functioning dual controls.

Equivalent Level of Safety

By their design, UAS lack fully functional dual controls. Instead, flight control is accomplished through the use of a control box that communications with the aircraft via ra dio transmission.

The equivalent level of safety may be assured since an UAS carries neither pilot n or passengers and in lig ht of its size and speed. The FAA has approved exemptions for flight training without fully functional dual controls for aircraft and for flight instruction in experimental aircraft. See,

e.g. , Exemption Nos. 5778K, 9862A.

H. 14 CFR § 9 1.119: Minimum Saf e Altitudes

Good Drones requests an exemption from the minimum safe altitude requirement, prescribed

under 14 CFR § 91.119 . Specifically, the provision sets out:Page 9 of 13 Except when necessary for takeoff or landing, no person may operate an aircraft below

the fo llowing altitudes:

(a) Anywhere. An altitude allowing, if a power unit fails, an emergency landing without undue hazard to persons or property on the surface.

(b) Over congested areas. Over any congested area of a city, town, or settlement, or over

any open air assembly of persons, an altitude of 1,000 feet above the highest obstacle within a horizontal radius of 2,000 feet of the aircraft.

(c) Over other than congested areas. An altitude of 500 feet above the surface, except over open water or sparsely populated areas. In those cases, the aircraft may not be operated closer than 500 feet to any person, vessel, vehicle, or structure.

However, helicopters may operate at less than the minimums when it can be done “without hazard to persons or property on t he surface,” provided that each helicopter operator complies with any routes or altitudes the FAA specifically prescribed.

Equivalent Level of Safety

As this exemption requests authority to ope rate an UAS at altitudes up to 5 00 feet above ground

level a nd not more than 200 feet above an elevated platform from which filming is planned, an exemption is necessary to allow such operations.

Compared to flight of normal aircraft, Good Drones’ UAS weigh 55 lbs or less , and given the lack of flammable fuel, an y risk associated with these operations is far less than those that presently exist with conventional aircraft. An equivalent level of safety will be achieved given the size, weight, and speed of the UAS, as well as the location where it is operated. As se t forth

in the Manual s , the sUAS will be operated in a predetermined area, where buildings and people will not be exposed to operations without their pre

- obtained consent. Because of the advance notice to the property owners and participants, all affected individuals will be well aware of the planned flight operations as s et forth in the Manual s . Furthermore, by operating at such lower altitudes, the UAS will not interfere with aircraft that are subject to the minimum safe altitude regulations.

I. 14 CFR § 9 1.121: Altimeter Settings

Good Drones seeks an exemption from 14 CFR 91.121, which requires a person operating an aircraft to maintain cruising altitude or flight level by reference to an altimeter that is set to the elevation of the departure airport or barometric pressure. An exemption is required because the

UAS does not have a barometric altimeter but a GPS altitude indicator

.

Equivalent Level of Safety

An equivalent level of safety will be achieved by following the procedures set forth in the

Manual s

. Good Drones will confirm the altitude of the launch site shown on the GPS altitude indicator before flight. Moreover, the Operator will use the GPS altitude indic ator to constantly

monitor the UAS's altitude , thus ensuring operation at safe altitudes.Page 10 of 13 J. 14 CFR § 91. 151(a): Fuel Requirements for Flight in VFR Conditions

Good Drones requests an exemption from 14 CFR 91.151(a)’s fuel requirements for flight in VFR conditions. That provision states:

(a) No person may begin a flight in an airplane under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing and, assuming normal cruising speed

— (1) During the day, to fly after that for at least 30 minutes; or (2) At night, to fly after that for at least 45 minutes.

The batter ie s powering Good Drones’ UAS Inspire 1 provide 18 minutes of maximum of powered flight time and UAS Phantom 3 23 minutes maximum of powered flight. To meet the

30

- minute reserve requirement, UAS flights would b e limited to approximately 10 minutes in length. Given the limitations on the UAS’s flight area and location of its operations within a predetermined area, a safety margin based on a reserve amount of batter y life is needed.

Equivalent Level of Safety

An equivalent l evel of safety will be achieved because the operations will be conducted on

- site

without s ignificant transit time by the UAS. All flights will be planned to terminate with no less than 25% reserve battery power still available. This restriction would be mo re than adequate to return the UAS safely to its planned landing zone from anywhere in its confined area of operation even in the event of an unexpected occurrence. Operation of the UAS with less than 30

minutes of reserve fuel does not i nclude the type of risks Section 91.151(a) was intended to

alleviate

, provided the size and speed of the small UAS as well as the proximity of the flight operation to the landing zone. Moreover, operation will be limited to controlled areas where only people and property ow ners who have signed waivers will be allowed.

K. 14 CFR § 91.203(a), (b): Carrying Aircraft Certification and Registration

Pursuant to 14 CFR § 91.203(a) and (b), for one to operate a civil aircraft, that aircraft must have “an appropriate airworthiness certificate . . . . displayed at the cabin or cockpit entrance so that is legible to passengers or crew.” The UAS, provided its weight of less than 55 lbs. and its operation without a pilot onboard, has no ability or place to carry certification and regis tration

documents.

Equivalent Level of Safety

An equivalent level of safety may be achieved by keeping these documents at ground control point where the Operator will have immediate access, to the extent that these documents are applicable to the UAS.

T he FAA has issued exemptions to this regulation, including Exemption Nos. 9565, 9789, and

10700.Page 11 of 13 L. 14 CFR §§ 91.405(a); 91.407(a)(1); 91.407(a)(2); 91.417(a), (b): Maintenance Inspections

Good Drones also seeks an exemption from the maintenance inspection requirements contained

in 14 CFR §§ 91.405(a), 91.407(a)(1), 91.409(a)(2), 91.417(a) and (b), which specify maintenance and inspection standards with reference to 14 CFR Part 43. These sections and Part 43 apply only to aircraft with an airworthiness certificate, and, as such, do not apply to Good

Drones.

Equivalent Level of Safety

An equivalent level of safety will be achieved because maintenance and inspections will be perform ed pursuant to the Manuals. As detailed in the Manual s , the O perator will ensure the UAS is in working order prior to flight, perform required maintenance, and keep a log of any maintenance performed. The O perator is the person most familiar with the aircr aft and best suited to maintain the aircraft in an airworthy condition to provide the equivalent level of safety.

I f mechanical issues arise, the UAS s ’ size and c arrying capacity as well as the fact flight operations will only take place in restricted areas for limited periods of time during daylight

hours creates less risk than that associated with conventional rotorcraft performing the same operation.

M. 14 CFR § 91.205(a), (b), (c): Instrument and Equipment Requirements

Section 91.305 provides a mi nimum set of instruments and equipment require d for day and night VFR flight for civil aircraft with a n airworthiness certificate

.

Equivalent Level of Safety

Should Good Drones’ request for an exemption from an airworthiness certificate be granted, an exemption under 14 CFR § 91. 205 is also necessary. Further, d ue to the small size of Good Drones’ UASs, it would be impossible to carry many of the instruments required under Section

91. 205 (b) and (c). Nonetheless, an equivalent level of safety may be achieved by visual contact

with the UAS and indications provided via the controller . The Manual s further delineate the means by which critical UAS flight information may be monitored, including GPS, battery reserve, and airspeed.Page 12 of 13 VI. Public Interest

Granting Good Drones an exemption furthers the public interest. National policy set by Congress favors early integration of UAS into the NAS in controlled, safe working environments, such as those proposed in this petition. Good Drones aims to help facili tate safe integration of UAS into mainstream use in the following areas:

• Education

• Humanitarian Work

• Environment

• Aerial Video and Photographs

• Site

- Inspections

• Real Estate

• Media and Advertising

Further, the use of UASs for aerial data collection for the af orementioned purposes , be it photography or videography

, addresses the common public concern of safety, since the operation of UASs, as described herein, is controlled and pre

- determined. A n unforeseen UAS incident causes less disruption than traditional a ircraft.

Such use of aerial data collection with UAS, rather than manned aircraft, also mitigates noise and pollution public concerns. By using batter power, the UAS produces no air pollution, and UASs

are the most environmentally conscious alternative to piston or turbine powered rotorcraft. UAS s also eliminate noise pollution as its battery

- powered motors are barely audible during takeoff phase, and a UAS cannot be heard when operating more than 100 feet above ground level.

Substantial risk to life and pro perty in the air and on the ground , often associated with traditional manned aircraft operations, is either substantially reduced or completely eliminated through the use of UAS to conduct aerial data collection. The small size and weight, with the lack of onboard crew, creates less physical potential for collateral damage to life and property on the ground and in the air. The UAS contains no reactive or combustible materials, substantially diminishing the risk of fire or explosions.

Above all, granting t his exemption will help the FAA devise future rules regarding UAS operations, maintenance, and crew qualification. The exemption will help advance knowledge in the burgeoning field of commercial UAS operations.

VII. Federal Register Summary

Pursuant to 14 CFR Part 11, the following summary is provided for publication in the Federal Register:

Good Drones LLC seeks an exemption from the following rules: 14 CFR Part 21, Subpart H; 14 CFR § 45.23(b) ; 14 CFR § 61.113 (a), (b) ; 14 CFR § 91.7 ; 14 CFR § 91.205(a), (b), (c) ; 14 CFR §§ 91.405(a); 91.407(a)(1); 91.407(a)(2); 91.417(a), (b) ; 14 CFR § 91.203(a), (b) ; 14 CFR § 91.151(a) ; 14 CFR § 91.121 ; 14 CFR § 91.119 ; 14 CFR §

91.109 ; 14 CFR § 91.103 ; 14 CFR § 91.9(b)(2)

.Page 13 of 13 Approval of this exemption request allows Good Drones to conduct commercial operations with small and lightweight unmanned aerial systems , weighing 55 lbs or less and powered by

batteries . Good Drones leverages drone technology to find solutions to pressing social problems,

and it will conduct UAS ope rations to promote education, assist in humanitarian response, monitor the environment, and promote communication. In general UAS operations are intended

to be conducted away from congested areas and airports. The UASs will carry neither passengers

n or cre w and, therefore, will not expose them to the risks associated with manned aircraft flights.

The operation of small UASs, conducted in the strict conditions outline above, will provide an equivalent level of safety supporting the grant of the exemptions r equested herein. These lightweight aircraft operate at slow speed, close to the ground, and in a sterile environment and, as a result, achieve a high level of safety.

VIII. Conclusion

For the foregoing reasons, Good Drones requests the exemptions detailed herein. Satisfaction provided in Section 333 of the Reform Act of 2012

— size, weight, speed, operating capabilities, proximity to airport and populated areas and operation within visual line of sight and national security

— p rovide more than adequate justification for the grant of the requested exemptions, allowing commercial operation of Good Drones’ UASs.

Please do not hesitate to contact, should you have any questions and concerns.

Respectfully submitted

,

Me h d i Salehi

Co

- Founder

Good Drones